Modern slavery act statement

Trafalgar House Pensions Administration Limited (“we” or “our”) is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of our local community.

This is our first statement on the anti-slavery and human trafficking measures implemented across our business and is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Our organisation

We are a specialist third-party pensions administrator based in the City of London.  Supplying services to UK occupational pension schemes for over ten years, we built a reputation for quality and service.

Founded in 2006 by the Trustee of the Trafalgar House Pension Trust, we were created to provide an alternative, high-quality solution to an industry decayed by years of underinvestment and falling standards. Our vision is to set the highest standard of pensions administration services by any recognised measure and we will achieve this through sustained investment in our people, processes and systems.

Supplying all services from our central London offices, we attract clients who value our in-house culture of member quality and the technology focus and innovation that comes from the third-party administration market.

Since being established, we have grown into a highly regarded defined benefit specialist, and have built an impressive portfolio of third-party clients that include some of the UK's best-known brands.

We work proactively and constructively with our clients, the market and our suppliers to improve the quality and standards of pension provision in the UK.  Our values influence the way we think, communicate, and behave as an organisation and govern the interaction we have with our clients, customers and the pensions market. 

Our supply chain

As a financial services business, our supply chain consists primarily of UK service providers whose employees have qualifications and skills that are unlikely to be exploited through forced labour. We assess the risk of modern slavery and human trafficking occurring in our business to be low, but we recognise that no organisation can consider itself immune or afford to be complacent.

Our supply chains include third party suppliers of products and services for our operation. These include, amongst others, suppliers of the following products and services:

  • Audio-visual equipment/service
  • Catering products and services
  • Consultancy services
  • Couriers
  • Financial services
  • Food and beverages
  • Insurance and banking services
  • IT equipment/software/hardware/services
  • Maintenance services
  • Marketing/advertising/design services
  • Photography
  • Professional services
  • Property management services
  • Recruitment services
  • Security services
  • Supplies for our offices and other sundries
  • Training services
  • Travel and accommodation services
  • Utilities


Anti-slavery and human trafficking policy

We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain. We comply with all applicable labour laws relating to working terms and conditions, including pay, and we place great emphasis on the fair and equal treatment of all our staff.  All our staff (including agency workers) are paid at least the London Living Wage.

Our Anti-Slavery and Human Trafficking Policy (the “Policy”) makes clear our zero-tolerance approach to modern slavery.  It shows our commitment to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. The Board of Directors has overall responsibility for ensuring the Policy complies with our legal and ethical obligations, and that all those under our control comply with it.

We provide training to staff on the Policy and on the risk that the business faces from modern slavery in its supply chains.

Supplier Due Diligence

We expect all our consultants, contractors, suppliers and other business partners (together “Suppliers”) to adopt the same high standards that we adhere to.  As part of the contracting process, where appropriate, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our Suppliers will hold their own Suppliers to the same high standards.

Our standard terms and conditions for Suppliers include an express obligation that they comply with the Modern Slavery Act 2015 in both letter and spirit.

As part of the process of identifying and assessing any actual or potential involvement in modern slavery in our supply chain, we require those employees responsible for procuring services to consider the risk of potential issues relating to modern slavery through our supplier onboarding process. We encourage openness and will support anyone who raises genuine concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains.

We use due diligence processes to risk assess Suppliers prior to contracting with them for their services. Once screened, suppliers will be subject to continuous monitoring. 

Assessment of Effectiveness

This statement constitutes our anti-slavery and human trafficking statement for the financial year ending 31 December 2018.  We will continue to assess the effectiveness of the measures we take and we will regularly review and refine our policies and procedures in relation to modern slavery and human trafficking and will include updates on any actions we take in future statements.

This statement has been approved Trafalgar House Pensions Administrations's Board of Directors. A revised statement, detailing the steps taken and improvements made, will be published on our website each year at www.trafalgarhouse.co.uk.

DATED: 21 February 2019